Child custody; Legal custody; Findings on the statutory best-interest factors (MCL 722.23); Factors (h), (j), & (l)

Concluding that the trial court’s findings on best-interest factors (h), (j), and (l) were not against the great weight of the evidence, the court held that it did not abuse its discretion when awarding sole legal custody to plaintiff-mother. After a prior remand from the court, the parties stipulated that the children had a custodial environment with both of them, and the trial court found that “the best-interest factors were equal except for factors (h), (j), and (l), which favored plaintiff.” On appeal, the court determined that “the trial court properly considered the children’s home records, including their relationships with their parents, in accordance with factor (h). For factor (j), the parties’ ability and willingness to facilitate relationships between the children and parents, the trial court considered the parties’ histories including defendant’s past lack of willingness to facilitate the relationships, as well as [his] more recent unilateral decisions. Finally,” as to other factors under (l), it “reasonably found that the parties were unable to cooperate and agree concerning important decisions on the children’s welfare such that joint legal custody, compared to sole legal custody, was not in the children’s best interests.” The court concluded that, focusing “on the children’s interests, plaintiff appeared to be the best party to serve the role as sole legal custodian given defendant’s previous actions.” The court also found that “the trial court debunked defendant’s main complaint with plaintiff as the sole legal custodian by explaining that he still had access to the children’s school information and thereby could maintain involvement in critical areas of” their lives. Affirmed.